please
e mail your support for the new forest service
proposal to encourage use of ecologically appropriate native plants in
revegetation and rehabilition projects

ACTION:

Several people have
asked for brief talking points for preparing their own comments on the Forest
Service proposed Native Plants Policy. Some thoughts are
below.

The Native Plant Conservation
Campaign's comment letter is also pasted in full in the BACKGROUND section for
those wishing for more detailed information.

****Comments may be
sent by e mail to nativeplant@... and are due
by AUGUST 24.****

The Forest Service
needs to hear that we commend the agency for their landmark proposal to use
native plants in these projects (the USFS is the first agency to propose a
native plant policy nationwide) BUT

(i)The
definitions of "native plant" and "genetically appropriate" plant materials are
INADEQUATE in the under the current proposal.

(ii)The
agency must select native plant materials based, not on the proposed
definitions, but on the best available scientific definitions of "native" or
"genetically appropriate"

(iii)Determinations of
ecological or genetic "appropriateness" of a particular plant for a particular
site or project must be made after thorough scientific review by qualified and
trained journey-level plant scientists

(iv)The
Forest Service must provide sufficient training (based on best available
science) to botanists, plant geneticists and other plant scientists who will be
making such determinations

(v)It may be
helpful for the agency to provide guidance regarding what is NOT "native" or
"genetically appropriate" rather than attempting to create one-size-fits-all
definitions of these terms.

(vi)Finally,
the agency must ensure adequate staffing in botany and plant science programs so
that qualified agency staff are available to participate in revegetation and
rehabilitation planning. Currently the agency is severely understaffing in
botany.

BACKGROUND

The Forest Service
has proposed new Forest Service Manual (FSM) rules directing that "genetically
appropriate" native plants be used in rehabilitation and revegetation of areas
damaged by fire, roadbuilding, logging or other activities.

The
USFS is the first agency to propose a native
plant policy at the national level; however several Forest Service regions
including Region 6 (Pacific Northwest), Region 5 (
California ), and Region 8 ( Southeast
US ) already have some version of this policy. Making the policy
uniform across all regions will help the FS better to work with nurseries and
other native plant seed and materials providers. One of the key benefits of this
policy should be a boost to this already expanding industry. Unlike other
activities and industries subsidized by the Forest Service and other federal
agencies, such as livestock grazing, logging and roadbuilding, encouraging
propagation of native plants should be ecologically beneficial to the public as
well as economically beneficial to the (generally small) nurseries and other
businesses involved.

The most problematic
section of the policy centers on its definitions of "noxious weed", "native
plant", and "genetically appropriate". The proposed definitions are
inadequate in the policy's current form. NPCC has proposed some possible
definitions in our comments (see below). However, because "native plant" and
"genetically appropriate" are extremely difficult - if not impossible - to
define correctly for all species and all ecosystems, we have also proposed that
qualified and trained botanists, familiar with the site and the local flora, are
critical to selecting plant materials that are appropriate for each project.

The Forest Service
may also wish to provide further guidance regarding appropriate native plant
materials in the Forest Service Handbook. Such guidance should be subject to
public review.

The NPCC is a project of the Center
for Biological Diversity. We are a nationwide network of native plant science
and conservation organizations. Currently the NPCC includes 34 affiliate native
plant societies, botanic gardens, museums, and arboreta, representing more than
75,000 scientists and laypersons nationwide. NPCC members rely on National
Forests, other public lands and botanical resources for enjoyment, education,
research, and recreation. NPCC affiliate organizations and their members work
closely with state and federal agencies to manage and conserve native plants and
ecosystems. We provide volunteer labor, botanical expertise and scientific
information to help public and private land managers to conserve our nation's
unique flora.

We commend the Forest Service for
taking this step towards the increased use of native plants in revegetation and
rehabilitation projects. Revegetation of damaged areas with local, ecologically
appropriate native plants restores habitat for native fish and wildlife,
including threatened, endangered, sensitive and other rare and imperiled plants
and wildlife; maintains critical ecosystem processes such as hydrologic and fire
regimes, and guards against infestations by exotic noxious weeds, pest, and
disease organisms. Use of native plants can hasten the re-establishment
recreation opportunities for the public. Finally, as the Proposal's "Objectives"
section states, increased federal use of local native plant materials will
encourage businesses (nurseries, seed producers) that produce such materials and
increase availability of local natives to other agencies and the public.

All of these are extremely desirable
outcomes. Again, we commend the Forest Service for this step to improve plant
selection policy in this way.

However, we do have some concerns
about the policy section of the Proposal:

1.Proposed FSM § 2070.45 states that
Forest and Grassland Supervisors may "delegate the
authority to use genetically appropriate native and non-native plant materials
in revegetation projects."

This direction fails to
designate criteria or qualifications for staff delegated to decide what plants
are suitable for use. The Proposal should be amended to require that all plant
material decisions should be made by a qualified journey-level (generally
defined in the FSM as GS-11 or higher) botanist or other plant scientist.
Further, all NEPA documents associated with projects using the Proposal should
contain documentation of the facts and reasoning underlying the choice of plant
material.

We also have concerns
in the "Definitions" Section

2.Proposed §2070.5 defines "Genetically appropriate" as

"A plant adapted to target site
conditions (e.g., has good establishment, vigor, and reproductive capabilities);
sufficiently diverse to respond and adapt to changing climates and environment
conditions; unlikely to cause genetic contamination and undermine local
adaptations, community interactions, and function of resident native species
within the ecosystem; unlikely to become (unnaturally or inappropriately)
invasive and displace other native species; unlikely to be a source of
non-native invasive pathogens; likely to maintain critical connections with
pollinators."

This definition should
be strengthened. The proposed definition sets no limits on whether "appropriate
plants" should be considered generally native, much less native to the project
area. This section should (i) refer back to Proposed FSM § 2070.3 to reinforce
the direction that native plants should be preferentially used and sets limits
on when and what type of non-native plants may be used under this Proposal; and
(ii) add language giving preference to "local native species" (see below for
suggested definitions for local native).

3."Native plant" is defined as "All indigenous,
terrestrial, and aquatic plant species that evolved naturally in an ecosystem."

This should be
strengthened to at least meet the standard set in the February 3, 1999
Presidential Executive Order:

""Native species" means, with
respect to a particular ecosystem, a species that, other than as a result of an
introduction, historically occurred or currently occurs in that
ecosystem."

Other
definitions under discussion in the botanical community
include

"A plant species that
occurs naturally in a particular area where only the biotic and non-human biotic
factors determine its presence and evolution."

"a particular species
which would have a reasonable probability of existing on a particular site
without any past human intervention. [In this case, the determination of what
constitutes a 'site'] would be the determining factor - it could be a mountain
range or a single bog."

Under the last
definition, site would be one of the factors to be determined by the qualified
botanist referred to above.

These
definitions all provide clearer and more specific direction regarding what
constitutes "an ecosystem" under the Proposal. Specifically, all these
definitions limit "native" species to those that occur or would occur in the
"ecosystem" or "site" in the absence of human
intervention.

4.Noxious weeds. This definition should be strengthened
to include invasive species listed by state, regional or local Invasive Plant
Councils such as the California Invasive Plant Council, the Florida Exotic Pest
Plant Council, or the federal Plant Conservation Alliance Alien Plant Working
Group. Official state and federal noxious weed lists often do not include all of
the destructive invasive exotic plants that are of concern in a particular area.

5.Restoration is defined as "Assisting the recovery of
an ecosystem that has been degraded, damaged, or destroyed (including) the
re-establishment of the pre-existing biotic integrity in terms of species
composition and community structure.

As above, this should
be strengthened and clarified to promote restoration of ecosystems to conditions
that existed or would exist in the absence of human intervention.

We submit these comments fully
understanding that the structure, processes or species composition of ecosystems
"in the absence of human intervention" is not always known, in some cases cannot
be known, and that some ecosystem damage prevents restoration to such a
condition. However, scientific review, analysis, and documentation by qualified
journey level botanists and ecologists are needed to determine when full
restoration to pre-intervention condition can be achieved.

We hope these comments
are useful. Please contact me at any time if I or the Native Plant Conservation
Campaign can be of assistance.